Hard to believe that my last post was more than a month ago. Things have been happening so fast and furiously of late that it feels just like yesterday and also like years ago. Now that the election is over, we have a historic opportunity and challenge in moving our economic and environmental policy forward, but we also face a real risk of the Bush administration in its last flailing gasps derailing foundational policies that we will need to chart our way forward. This is especially true in the area of biofuels.
The renewable fuel standard is far from a perfect policy tool, but it does include groundbreaking lifecycle GHG standards and renewable biomass sourcing safeguards. The lifecycle emissions accounting especially is a fundamental tool that we need to get right if we are to have any hope of knowing if the biofuels we're developing are part of the climate solution or part of the problem.
Recently there have been a spate of articles (e.g. this and this) about how EPA is coming under political pressure to ignore a major source of GHG pollution--emissions from changes in land-use induced by biofuels. Much of this pressure has come in the form of letters from industry groups (Bio's letter, Soybean Growers' letter) and a few academics. Even the Brazilian government has sent a letter. Some would have EPA simply ignore these emissions--also known as emissions from indirect land-use change (ILUC). Others would have EPA only propose a method for calculating these emissions and not any draft values.
So far these letters have been met by two countervailing letters from environmental groups. One is from the Clean Air Task Force, Environmental Working Group, and Friends of the Earth and is general; the other is from Conservation International, Defenders of Wildlife, and the National Wildlife Federation and addresses some technical issues.
On Monday, EDF, FOE, UCS, NWF, and NRDC will send EPA (and cc USDA) another letter making the following points:
- By law EPA must include the emissions from ILUC (this post has the specific language)
- ILUC is real and big for certain sources of biomass, and thus EPA must include these emissions to ensure that biofuels produce real GHG benefits instead of increased pollution
- EPA has been engaged in a rigorous rule making process that has drawn on the best available science and economics and the rule will continue to improve through the notice and comment process
- There is ample biomass that incurs little or no ILUC emissions to launch the advanced biofuels industry and comply with the RFS requirements
These arguments are also being played out to OMB, where industry and environmental groups have made their case, and out in California where the Air Resource Board is wrestling (here's ARB's website on the LCFS) with exactly the same challenge in terms of developing a lifecycle GHG accounting protocol. (The letter debate to CARB started this summer as I've written about before.)
In many ways, it's this letter to CARB, signed by many in the advanced biofuels industry under the auspices of the New Fuels Alliance, that I find most disturbing. The letter freely mixes good points that could serve as helpful, constructive input into a good ILUC accounting with philosophical arguments for ignoring emissions from ILUC and misleading claims about the science, scale, and importance of including these emissions. The letter really deserves a post all its own, but let me just address a few examples of the type of arguments made:
- The letter makes a good point that accounting for ILUC should take particular care to assess the impacts of some of the most promising ways of minimizing and avoiding these emissions so that we can identify the best paths forward for the industry.
- The letter make much of the uncertainty surrounding precise estimates of the ILUC emissions from different sources of biomass, but uncertainty is not an excuse for inaction. This same argument has been made by opponents of action on global warming and has put our world at great peril. The science and economics are certain enough for a high degree of accuracy about the relative scale of these emissions and CARB and EPA are drawing on the best science and modeling.
- Finally the letter spends a lot of time making claims of injustice and risk because indirect emissions from petroleum have not been included in CARB's draft. While certainly economically mitigated emissions for all fuels should be included, to the best of my knowledge no one has done any analysis to suggest any such source of emissions related to petroleum is large or even presented a logic for how such a source might be large. Heck, I want to believe, but I can't think of a source (not saying much, I'll readily admit) and we should not ignore now what we know can be large because we might in the future come up with one.
Two last points: one, as I've said before the first and best way to deal with ILUC emissions is to regulate them directly. We need an international cap on GHG emissions that includes emissions from land-use change. And when we get one, we should stop regulating these emissions from biofuels. At that point those emissions will be capped and any increase caused by biofuels will have to be offset elsewhere in the system. But let's be honest, such an agreement is years away and in the meantime the biofuels industry will invest billions of dollars (I hope) in facilities and feedstocks. Federal and state mandates and incentives should be spent making sure these investments have the greatest chance of providing real benefits and surviving under such a future cap.
And two, I continue to believe that the advanced biofuels industry is missing an opportunity to distinguish themselves in the eye of the public and investors from the first generation industry by not embracing ILUC accounting. The news has been full of articles about the first generation of ethanol investment struggling. If enough of the industry keeps insisting to regulators that it can't survive if the emissions from ILUC are part of the criteria for public support, eventually everyone is going to believe them and that will spell the end of public support, investment and one of the industries main reasons for being.
It's time for industry leaders to stop trying to convince EPA and CARB to ignore ILUC emissions and to start signing on to letters that say "Yes we can, and here's how."